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:~:

.,

-

:~: . , - BY FACSIMILE The Honorable States United 500 New York, Pearl Robert P.
:~: . , - BY FACSIMILE The Honorable States United 500 New York, Pearl Robert P.
:~: . , - BY FACSIMILE The Honorable States United 500 New York, Pearl Robert P.

BY FACSIMILE

The Honorable

States

United

500

New York,

Pearl

Robert

P.

U.S,. Department of Justice

United States Attorney Southern District ofNew York

The Silvif) J. Mollo Building

One Saint Andrew 's Plaza

NL'W York, New York 10007

Saint Andrew 's Plaza NL'W York, New York 10007 Patterson District Judge 10007 street NY Re:

Patterson

District Judge

10007

street

NY

Re:

Un:!.ted

52

States v.

Danie1 B.

07

Cr.

541

(RPP)

Karron,

Dear Judge

Patterson:

The Government

respectfully

submits this

letter to move

in

witnesses

limine to

admit

certain testimony that

give.

are expected to

a

number of Government

I

.

Background

A number

of

Government

witnesses

who

worked with

the

defendant

that,

knowledge

known as Quickbooks.

their everyday duties and responsibilities,

at

Computer Aided Surgery,

they were employed at

the

Inc.

("CASI")

will

testify

while

CASI,

they had personal,

direct

about

defendant's electronic bookkeeping

They will

further

testify that,

system,

as part of

they were asked by

the

defendant

to make data

entries

regarding the

defendant's and

CASI's

entries,

expenditures

however,

in Quickbooks.

After they made these

the defendant

frequently altered their work -

witnesses

for

example,

by changing what

these

characterized as an

"unallowable"

or

"non-grant-related expense" back into an

~allowable" or ~grant-related expense"

in the Quickbooks ledger.

These witnesses will

collectively,

stop "mucking around the books," but the

his conduct and repeatedly violated the controls that his

employees

testify that,

result

individually and

occasions to

they told

to

the defendant on multiple

As

a

defendant persisted in

of this

own

tug-of-war,

sought

implement.

the Quickbooks ledger was not

a

stable document but was

constantly in a state of

flux .

200'd

2900

~89

212

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80:12 800~-00-Nnr

------------------

The Honorable

June

page

2,

2

2008

Robert

P.

II. Re~evance

The Government

Patterson

submits that

such

testimony is

directly

relevant to the defendant's state of mind and, hence, should be admissible as evidence at trial. From defense counsel's opening statement this afternoon, it is apparent that the defense intends to argue to the jury that the defendant had nothing to hide, that while mistakes were made, they were made by other people, and

that the defendant had no criminal intent to misapply grant funds. Evidence that the defendant attempted actively to interfere with accurate bookkeeping showing how grant funds were spent at CASI goes directly to the defendant's criminal intent.

III. Non-hearsay

The Government

also

respectfully submits that such

testimony

that,

is

should the

not hearsay.

Defense

counsel

has

indicated to

"Quickbooks

ledger"

not be admitted into

us

evidence,

he might

object

to witness testimony about the

ledger

on hearsay

grounds.

For

the

reasons

set

forth

below,

the

Government

submits

that

any such hearsay objections

are

 

meritless.

 

ledger is

not for the truth of the information contained in the ledger.

Indeed, the Government's argument is just the opposite - that, as a result of the defendant's interference with the work.of his

auditors J bookkeepers, and business managers, the

frequently inaccurate. The witnesses' testimony about the ledger is offered for a different, non-hearsay, purpose: to show simply

that the defendant made alterations to Quickbooks against the

warnings of his employees - alterations of which these witnesses

had direct,

illuminate the defendant's state of mind while the misapplication of CASI's and the grant's funds was occurring.

require the admissibility of the ledger

as

testimony is

of the defendant's

CASI's

witnesses making certain bookkeeping entries,

changed back in

comprehensive document that

Quickbooks

Because

directly observed,

the typical percipient witness who testifies

2

The

Government witnesses'

testimony about the

ledger was

personal

knowledge -

to

and which would,

in turn,

Furthermore,

of,

a precondition

to

or alternative

to,

such witnesses'

As noted

above,

require the

impossible.

because

them

is

no

they

constant changes to

the Quickbooks entries,

with the

have

There

ledger was

that

the

in a constant state of change,

records

every alteration

are

only to

a manner that

captures

suited the defendant.

every

keystroke made in

the defendant made.

as

to

what

Government's witnesses

however,

testifying

their testimony is no different from

as

to

what

he

SOO'd

Z900

L89

ztz

witnesses however, testifying their testimony is no different from as to what he SOO'd Z900 L89

vo:tZ

800Z-Z0-Nnr

vOG d Tv&10J.

The Honorable

Robert

P.

June

2,

2008

Page

3

Patterson

observed

these witnesses'

opposed to,

say,

accident

hearsay.

from his

And

just

own

car

as

senses.

The mere

fact

that the subject of

as

observation was an evolving document -

a

accident -

does not make their testimony

testimony about

a

car

an eyewitness's

is not made any less admissible because his observations

were

not

recorded

on camera,

the Government witnesses's testimony

about

the

changing ledger is

not any less

admissible because

there does not exist a contemporaneous record documenting such

changes

over time.

'IV ~

Expert Testimony

Finally,

at

least with respect to two of the

Government's

witnesses -

Joan Hayes and Belinda

Riley -

who are

expected to

be qualified

as

expert witnesses~ the

Rules

of

~

Evidence

underlying documents for their expert testimony to be admissible.

explicitly do not

require

the admissibility of the

Fed.

R. Evid. 703

("If of a type reasonably relied upon by

experts in the particular field in forming opinions or inferences

upon the

subject,

the facts

or data need not be admissible in

evidence

in order for

the opinion or inference to be admitted. H) .

v.

Conclusion

submits

For

that

the

foregoing

reasons,

the Government respectfully

the proffered te.stimony of Government witnesses

concerning changes to

hearsay evidence

Quickbooks

and admissible

the defendant made is

at trial.

non-

Respectfully submitted,

MICHAEL J.

United States Attorney

GARCIA

cc:

Ron Rubinstein,

Counsel to

Esq.

Daniel B.

By:

a·~d

Chi T.

Christian R.

Assistant United States Attorneys

Steve Kwok

Everdell

(212)

637-2415

/

(212)

637-2556

(by

fax

Karron

and email)

tOO'd

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2.,89

eTe

3

3JlddO S'AaNHO~lV 's'n

vo:Ye

BODe-eO-Nne

.,r-

FACSIMILE COVER SHEET

U.S. ATTORNEY'S OFFICE, S.D.N.Y. ONE ST. ANDREW·S PLAZA

NEW YORK, NEW YORK 10007

**************************************+*••*********************************

From:

Steve Kwok

Assistant United States Attorney

Phone:

(212) 637-2415

Fax:

(212) 637-2390

No. pages (including cover sheet): 4

Date sent:

June 2) 2008

***************************************************************************

j

i

j

_

_

-

···

-_·1

FOR OFFICIAL USE ONLY -

U.S. AlTORNEY FACSIMILE COMMUNICATION

i

 

!

1 The information contained in this facsimile message, and any and all accompanying documents. i

 

I constitute "for official use ontyY> information. This information is the property of ~e U.S. Attorney's Office. If you are not the intended recipient of this information, any disclosure, copying, distribution. or the taking of any action in reliance on this information is strictly

 

t

I

prohibited.

If you received this information in error, please notify us immediately by telephone

i

at the above n~

ana destroy the information.

!

 

i

 

_

_

*********************~******+******.***************************************

To:

To:

Re:

The Honorable Robert P. Patterson

212

805

7917

Mr. Ron Rubinstein

212-679-1844

JlS v. Karton. 5207 Cr. 541 (RPP)

Message:

Please see the attached letter.

Thank you.

lOO'd

2900 c!.89 ZlZ

3QIddO S'A3NHOllV

's'n

80:lZ

BOD2-Z0-Nnr

1

76K9KARA

Arraignment

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

2

---------------------

-------x

3

UNITED

STATES

OF AMERICA,

4

v.

07

CR

0541

(RPP)

5

DANIEL B.

KARRON,

6

Defendant.

7

------------------------------x

 

8

New York, N.Y. June 20, 2007

9

2:30

p.m.

10

 

Before:

 

11

 

HON.

ROBERT

P.

PATTERSON,

JR.,

12

 

District Judge

13

14

APPEARANCES

 

15

MICHAEL J.

GARCIA

 

United States Attorney for

the

16

Southern District

of New York

 
 

CHI

T.

STEVE KWOK

 

17

Assistant United States Attorney

 

18

RON RUBINSTEIN Attorney for

Defendant

 

19

20

21

22

23

24

25

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

2

 

76K9KARA

 

Arraignment

 

1

(In open courtj

case called)

2

THE DEPUTY

CLERK:

Is

the government

ready in

this

 

3

matter?

 

4

MR.

KWOK:

We

are.

Good afternoon,

your Honor,

Steve

5

Kwok

for

the

government.

 

6

 

THE

COURT:

Good afternoon,

Mr.

Kwok.

7

THE DEPUTY CLERK:

Defendant

ready in

this

matter?

8

MR.

RUBINSTEIN:

The

defendant

is

ready.

Good

9

afternoon,

your Honor.

The

defendant

is

represented by Ron

 

10

Rubinstein of Rubinstein and Corozzo.

 

11

 

THE

COURT:

Good afternoon,

Mr.

Rubinstein.

And good

12

afternoon Mr.

Karron.

 

13

 

This

is on for arraignment,

is

it?

14

MR.

KWOK:

Arraignment and presentment.

 

15

THE

COURT:

Excuse me?

 

16

MR.

KWOK:

Arraignment

and presentment.

 

17

THE

COURT:

All

right.

Daniel B.

Karron,

you have

a

18

right to remain silent.

You need not

make

any

statement.

Even

19

if you have already made statements to the authorities,

you

20

need not make any additional

statements.

Any

statement

you do

21

make

can be used against

you.

22

 

Is

the

defendant a

citizen of the United States?

 

23

MR.

RUBINSTEIN:

Yes,

your Honor.

 

24

THE

COURT:

Mr.

Karron,

you have

the

right

to be

25

represented by an attorney today and at all

future proceedings

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

3

 

76K9KARA

Arraignment

 

1

in this

case and if

you're unable to afford an attorney I

will

2

appoint an attorney to

represent you.

 

3

 

I

believe you're

represented by retained counsel;

is

4

that correct?

 

5

 

THE DEFENDANT:

That

is

correct.

 

6

THE COURT:

I'll go on to arraignment.

Daniel B.

 

7

Karron,

Mr.

Rubinstein,

have you seen a

copy of

the

indictment

8

charging the defendant with being an agent of

an organization

9

which received benefits

of more than ten

thousand dollars

under

10

a

federal

program and obtaining a property value

of more than

11

five

thousand dollars

which was under

the

control of

that

12

organization?

 

13

 

Have you

seen a

copy of

the

indictment charging the

14

defendant with one count,

violation of Title 18,

united States

15

Code,

Section 666.

 

16

 

MR.

RUBINSTEIN:

Yes,

your Honor.

I

have

seen it,

17

reviewed it

with the

defendant.

We

would waive

the public

 

18

reading and ask

the

court to enter a plea of not guilty on

19

behalf of Dr.

Karron.

 

20

 

THE COURT:

Dr.

Karron,

have you seen a

copy of

the

21

indictment charging you with obtaining

-- misapplying more than

22

five

thousand dollars

in federal

funds

from

an organization

23

receiving more than ten thousand dollars

in a single year under

24

a

federal program?

25

THE DEFENDANT:

Yes,

I

have.

 

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

4

 

76K9KARA

Arraignment

 

1

 

THE

COURT:

Have you discussed

the

charges

 

with

2

Mr.

Rubinstein?

 

3

 

THE DEFENDANT:

Yes,

I

have.

 

4

THE

COURT:

Do you wish

to

have

the

indictment

read to

5

you at

this

time or

6

 

THE DEFENDANT:

That's not necessary,

sir.

7

THE

COURT:

You don't.

You wish

to

waive

a

reading of

8

the

indictment?

 

9

 

THE DEFENDANT:

That

is

correct.

 

10

THE

COURT:

And you wish

a

plea of not guilty entered

11

at this

time

on your behalf?

 

12

THE DEFENDANT:

That

is

correct.

 

13

THE

COURT:

A plea

of

not

guilty will

be

entered on

14

behalf of

the

defendant at

this

time.

15

When will

the

government make

the

required discovery

16

to

the defense?

17

 

MR.

KWOK:

We

have

discovery.

I'd ask for about three

18

weeks

from Mr.

Rubinstein if

that's

satisfactory to

 

the

court.

19

 

THE

COURT:

So what

date?

 

20

MR.

KWOK:

July 11.

 

21

THE

COURT:

July II?

 

22

MR.

KWOK:

Yes.

 

23

THE

COURT:

July 11,

2007

for discovery to

 

the

24

defense.

25

 

How

long,

Mr.

Rubinstein,

would you

like

for any

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

5

     
 

76K9KARA

 

Arraignment

1

motions?

 

2

MR.

RUBINSTEIN:

Well,

your Honor,

what

lId ask if

 

3

your Honor could set

a

status conference after we get all

4

discovery.

Mr.

Kwok has

indicated that

the

discovery is

 

5

voluminous.

 

6

 

THE

COURT:

How many days

after July

11

do you wish

to

7

have--

 

8

MR.

RUBINSTEIN:

 

1 1 m going

away

on the

13 th

and I'll

 

9

be back on the

21st.

So

I

would ask

for

the

first

week

in

10

August,

your Honor,

to make motions.

 

11

 

THE

COURT:

All right.

 

12

THE DEPUTY CLERK:

 

August

2.

13

THE

COURT:

August

8.

14

MR.

RUBINSTEIN:

 

That's

fine,

your Honor.

 

15

MR.

KWOK:

Is

that

the

second?

 

16

THE DEPUTY CLERK:

 

Eighth.

 

17

THE

COURT:

Second or eighth?

 

18

MR.

RUBINSTEIN:

 

Prefer the eighth,

your Honor.

 

19

THE

COURT:

August

8.

Is

that for motions or to

 

20

advise us of motions?

 

21

 

MR.

RUBINSTEIN:

 

If

I

could advise you of

the motions

22

on that

day,

your Honor.

 

23

 

THE

COURT:

All

right.

Since

it's

voluminous

material

24

I

think

that's

fair.

25

 

I

would expect

the motions

to be made soon thereafter.

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

6

 

76K9KARA

 
 

Arraignment

1

So we'll

put

it

down

for

August

8

at

4:00.

2

MR.

RUBINSTEIN:

That's

fine,

your Honor.

 

3

MR.

KWOK:

That's

fine

for

the government.

 

4

THE

COURT:

Have

the

parties

agreed on a

bail package

5

or what is

the

situation with respect

to pretrial detention?

6

 

MR.

KWOK:

The

government's

position

is

that the

 

7

defendant

can be

released on his

own recognizance

but

I

was

8

just told by Mr.

Rubinstein

that

the defendant needs

to

travel

9

throughout

the

country

for

lecture purposes.

 

10

 

THE

COURT:

For what purposes?

11

MR.

KWOK:

For lecturing.

 

12

THE

COURT:

Oh.

13

MR.

KWOK:

For now

I

think the defendant can be

 

14

released on the

condition that he surrender his

passport,

which

15

he already did,

and no new applications

for

travel be made.

16

 

Once

the

defendant has

satisfied the condition of

17

securing two cosigners

for

a

$50,000

PRE,

then the government

18

would consent

to allowing him to

travel

for

those

lecture

 

19

opportunities.

 

20

 

THE

COURT:

Throughout

the United States?

 

21

MR.

KWOK:

I

was

told

that he only needs

to

go

to

the

22

District of Columbia and Philadelphia.

I'm not aware of other

23

locations.

 

24

 

MR.

RUBINSTEIN:

Your Honor,

he has

business

and he

25

travels

for

the purposes of his

business

and he

--

right now

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

7

 

76K9KARA

 

Arraignment

 

1

he's

involved in a

contract negotiation between the

company he

2

works

for out of Washington,

D.C.,

ATK,

and the

University of

 

3

Pennsylvania.

So he

anticipates

going to

Pennsylvania

in

the

4

near future

and also

to Washington,

D.C.

 

5

 

He may be

forced

to

sell his apartment in New York for

6

financial

reasons

and he would then

look to

reside with his

 

7

former

roommate

in Connecticut.

 

8

 

So we

surrendered him this

morning.

This

 

9

investigation has been going on I

think since

2004,

he's been

 

10

aware

of

it,

and we arranged a

voluntary surrender with the

11

passport.

 

12

I

would ask your Honor for

at

this

time

to

give him

 

13

permission to

go

to

Connecticut;

Philadelphia,

Pennsylvania;

14

and Washington,

D.C.

along with the

Southern and Eastern

 

15

Districts of New York until we secure these two suretors.

16

 

Does your Honor want us

to go before

the magistrate

 

17

with the

two

suretors,

or how should we arrange that?

 

18

THE

COURT:

Well,

you can go before

the magistrate

 

19

with two sureties

and the

U.S.

Attorney.

The

U.S.

Attorney,

I

20

gather,

wants

to approve the

sureties beforehand;

is that

 

21

right?

 

22

MR.

KWOK:

Yes,

of course.

 

23

THE

COURT:

So

as

I

understand the parties

agreed on

 

24

the personal recognizance bond signed by two sureties

 

25

satisfactory to the government?

SOUTHERN DISTRICT REPORTERS,

(212)

805

0300

P.C.

8

   
 

76K9KARA

Arraignment

1

 

MR.

RUBINSTEIN:

No,

your Honor

 

2

THE

COURT:

Is

that right?

 

3

MR.

RUBINSTEIN:

They've

agreed

 

4

THE

COURT:

What?

 

5

MR.

RUBINSTEIN:

They've

agreed temporarily

to

release

6

the

doctor on a personal recognizance bond,

his

own,

with

 

7

limited travel

rights.

 

8

 

THE

COURT:

Without

any sureties?

 

9

MR.

RUBINSTEIN:

Without any sureties.

10

THE

COURT:

Is

that correct?

 

I

just want to be sure.

11

MR.

KWOK:

No.

My position

is

that today Mr.

Karron

12

can be

released on his

own recognizance

but

even after

the

13

conditions are

satisfied

--

 

14

 

THE

COURT:

wait a minute.

Today the

parties

are

15

agreed he will be

released on his

own recognizance?

 

16

 

MR.

KWOK:

That's

correct.

 

17

THE

COURT:

When do

you

require

the

two

sureties

to

18

sign?

19

 

MR.

KWOK:

Within a

week.

 

20

THE

COURT:

Within a

week.

21

Is

that agreed upon,

Mr.

Rubinstein?

 

22

MR.

RUBINSTEIN:

Could we have

ten days,

your Honor,

23

that would be a week from Friday?

 

24

 

THE

COURT:

That's

fine.

Within a

week

from

Friday or

25

ten days

from

now he

will

provide

a

recognizance bond signed

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

9

   

Arraignment

 
 

76K9KARA

1

by

--

personal

recognizance bond for

$50,000

signed by two

 

2

sureties acceptable by the government.

 

3

 

MR.

KWOK:

That's

correct.

 

4

THE

COURT:

Now as

to

the areas which he may travel?

5

MR.

KWOK:

Exactly.

6

THE

COURT:

He

can travel,

as

I

understand

it,

to

the

7

District of Columbia,

to

Pennsylvania,

to New York,

and

8

Connecticut.

And any

further

travel would have to be upon

 

9

application to

the

court.

 

10

 

MR.

KWOK:

Exactly.

That's

the

government's position.

11

THE

COURT:

Is

that all

right,

Mr.

Rubinstein?

 

12

MR.

RUBINSTEIN:

Yes,

your Honor.

 

13

THE

COURT:

All

right.

Now,

then are

there

any other

14

conditions of

release

that

I

have

to be aware?

15

 

Surrender the passport.

 

16

MR.

KWOK:

Which he

already did

today.

17

THE

COURT:

He's

done

that.

 

18

MR.

KWOK:

And no

new applications.

 

19

THE

COURT:

And no

new applications

for a passport

 

20

will be made without notice to

the

government.

 

21

 

MR.

KWOK:

That's

correct,

your Honor.

22

THE

COURT:

Anything further?

 

23

MR.

KWOK:

The

only other

thing

from

the government is

24

we

would ask

for

the

exclusion of

time

to allow the government

25

to produce discovery and for

the defense

to

review

discovery

 

SOUTHERN DISTRICT REPORTERS,

P.C.

(212)

805-0300

10

 

76K9KARA

Arraignment

 

1

until our next appearance on August 8.

2

 

THE

COURT:

Wait a

minute.

Exclusion of

time.

You

3

just want an exclusion of time from the Speedy Trial Actj

is

 

4

that correct?

 

5

 

MR.

KWOK:

That's

correct.

 

6

THE

COURT:

Your application

is

granted.

Time will

be

7

excluded under

the

Speedy Trial Act until

August

8 because

8

discovery has

to be made,

and the unavailability of

defense

 

9

counsel

for

a

period of

time,

and for

an opportunity for

10

defense

to

review

that

discovery and determine whether any

11

motions

should be made.

Under those

conditions,

the exclusion

12

is granted.

 

13

 

MR.

KWOK:

Thank you,

your Honor.

 

14

THE

COURT:

Anything else?

 

15

MR.

KWOK:

Nothing

from

the

government.

 

16

MR.

RUBINSTEIN:

Nothing

from

the defense,

your Honor.

17

THE

COURT:

All right.

 

18

MR.

KWOK:

Thank you,

your Honor.

 

19

THE

COURT:

Thank you very much.

20

(Adj ourned)

 

21

 

22

23

24

25

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

1

770AAKARA

Arraignment

1

UNITED

STATES

DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

 

2

------------------------------x

 

3

UNITED

STATES

OF AMERICA,

4

v.

07

CR

541

(RPP)

5

DANIEL B.

KARRON,

 

6

Defendant.

7

------------------------------x

 

8

New York, N.Y.

9

July 24, 2007 4:00 p.m.

10

 

Before:

11

 

HON.

ROBERT

P.

PATTERSON,

JR.,

12

 

District Judge

13

14

APPEARANCES

 

15

MICHAEL J.

GARCIA

United States Attorney

for

the

16

Southern District

of New York

 

STEVE KWOK

17

Assistant United States Attorney

 

18

RONALD RUBINSTEIN Attorney for

Defendant Karron

19

20

21

22

23

24

25

SOUTHERN DISTRICT REPORTERS,

(212)

805-0300

P.C.

2

 

770AAKARA

 

Arraignment

 

1

 

(Case

called)

 

2

MR.

KWOK:

Steve Kwok,

for

the government.

 

3

MR.

RUBINSTEIN:

Defendant

is

ready for

the

4

arraignment

is

represented by Ron Rubinstein.

 

5

 

Good

afternoon,

your Honor.

 

6

THE

COURT:

Good afternoon,

Mr.

Rubinstein.

 

7

Good

afternoon,

Mr.

Karron.

 

8

I

have a

superseding

indictment here

charging

the

 

9

defendant with receiving

federal

benefits

in the one year

 

10

period

in excess

of

$10,000

and

converting

it

to his

own use

or

11

the use

of persons

other

than

the

rightful

owner,

$5,000

and

12

also

containing

the

forfeiture

allegation asking that

the

13

proceeds

of

the alleged

theft be

forfeited upon construction

 

14

for

the

substitute assets belonging to

the defendant.

In

that

15

event

to be forfeited

in

the

event

forfeitable

property is

no

 

16

longer pliable.

 

17

 

Daniel B.

Karron,

Mr.

Rubinstein,

have you

seen a

copy

18

of

the

superseding

indictment?

 

19

MR.

RUBINSTEIN:

We have,

your Honor.

 

20

THE

COURT:

Have you

discussed

it

where your

client?

 

21

MR.

RUBINSTEIN:

I

have,

your Honor.

 

22

THE

COURT:

Does

he wish

to

have

it

read

to

him at

 

23

this

time or

does

he waive

the reading?

 

24

 

MR.

RUBINSTEIN:

He waives

the reading,

your Honor.

 

25

THE

COURT:

All

right.

Mr.

Karron,

have you

seen a

SOUTHERN DISTRICT

REPORTERS,

(212)

805-0300

P.C.

3

 

770AAKARA

 

Arraignment

 

1

copy of

the

superseding

indictment?

2

THE

DEFENDANT:

Yes,

I